International Tax

Extension of Federal Tax Deadline Applies to Liabilities of Multinational Taxpayers by Arthur J. Dichter, JD, LLM

Posted on March 25, 2020 by Arthur Dichter

The IRS has clarified that the postponement of the due date for 2019 federal income tax filings and payments to July 15, 2020, also applies to installment payments of repatriation tax on foreign earnings and base erosion and anti-tax abuse tax (BEAT) that would otherwise be due on April 15. The Tax Cuts and Jobs Act […]

Tax-Efficient Planning Strategies for Art Collectors by Lewis Kevelson, CPA

Posted on January 09, 2020 by Lewis Kevelson

Art collectors who accumulate artwork over their lifetimes tend to have limited interest in selling any of the pieces in their collections, according to a recent study conducted by UBS. Instead, most collectors develop an emotional attachment to the artwork they acquire and prefer to display their collections in their homes for their own personal […]

New Procedures Provide U.S. Tax Relief to Some Expatriates by Arthur Dichter, JD, LLM

Posted on November 25, 2019 by Arthur Dichter

The IRS recently rolled out Relief Procedures for Certain Former Citizens (expat relief procedures), which is intended to help some former U.S. citizens who renounced or intend to renounce their U.S. citizenship come into compliance with their outstanding U.S. tax and filing obligations without incurring additional liabilities. Background on Expatriation Exit Tax There are […]

Are U.S. Visa Holders Subject to U.S. Income and Estate Taxes? by Tony Gutierrez, CPA

Posted on November 04, 2019 by Anthony Gutierrez

For many foreign persons, the U.S. tax system can be a complicated web of conflicting rules and exceptions, making compliance difficult, at best. One of the more complex challenges concerns the manner in which the U.S. imposes tax on foreign persons for income tax and estate and gift tax purposes. In general, the U.S. presumes […]

Considerations for Foreign Investors in U.S. Real Estate after Tax Reform by Ken Vitek, CPA

Posted on October 17, 2019 by Ken Vitek

U.S. real estate continued to attract foreign investors during the first half of 2019, thanks, in part, to a growing U.S. economy, low interest rates, and strong underlying fundamentals that support predictable cash flow and property appreciation. At the same time, the U.S. tax landscape has changed with the passage of the Tax Cuts and […]

Maximizing Donations to Foreign-Based Charities under Tax Reform UPDATED by Lewis Kevelson, CPA

Posted on October 08, 2019 by Lewis Kevelson

Donations that U.S. taxpayers make directly to foreign charities usually will not qualify for income tax deductions unless those charities are registered with the IRS as tax-exempt entities or there is relief available under a bilateral income tax treaty. In the rare instances when these conditions are met, the charitable deduction is available only to […]

EB-5 Visa Program is Alive and Well, But New Rules May Make it Harder to Use by Andrew Leonard, CPA

Posted on October 03, 2019 by Andrew Leonard

After 29 years, the U.S. government is making changes to its EB-5 visa program, which helps foreign citizens expedite U.S. residency in return for capital investment in commercial projects that create or preserve domestic jobs. Under new rules that go into effect on Nov. 21, 2019, it will become more expensive and more difficult for […]

U.S. Approves Long-Awaited Tax Treaties with 4 Ally Countries by James W. Spencer, CPA

Posted on September 27, 2019 by Jim Spencer

In the summer of 2019, the U.S. ratified updates to international tax treaties with four of the country’s allies that had been awaiting Senate approval for nearly a decade. The move yielded a collective sigh of relief from multinational businesses and their shareholders in Spain, Switzerland, Japan and Luxembourg that had been operating in an […]

Wayfair Decision Imposes New State Tax Burden on Foreign Businesses Selling into the U.S. UPDATED by Karen A. Lake, CPA

Posted on September 24, 2019 by Karen Lake

The U.S. Supreme Court’s 2018 decision in South Dakota v. Wayfair has had far-reaching impact on the state and local sales tax (SALT) obligations and previous competitive advantages of online and foreign businesses that sell products into the U.S. The court’s ruling eliminated the prevailing physical presence test, which required sellers to collect sales tax […]

Multinational Business May Want to Rethink Entity Choice and Other Elections by Andrew Leonard, CPA

Posted on August 22, 2019 by Andrew Leonard

The overhaul of the U.S. tax code was signed into law at the end of 2017, yet many taxpayers are continuing to conduct business as usual, paying little attention to how the new law impacts their tax liabilities for 2018 and beyond. To be sure, the Tax Cuts and Jobs Act (TCJA) in its original […]

Category: International Tax